In developing its policies
and procedures, a furnisher should address the following, as appropriate:
(a) Establishing and implementing a system for furnishing
information about consumers to consumer reporting agencies that is
appropriate to the nature, size, complexity, and scope of the furnisher’s
business operations.
(b) Using standard data reporting
formats and standard procedures for compiling and furnishing data,
where feasible, such as the electronic transmission of information
about consumers to consumer reporting agencies.
(c) Maintaining records for a reasonable period of time, not less
than any applicable recordkeeping requirement, in order to substantiate
the accuracy of any information about consumers it furnishes that
is subject to a direct dispute.
(d) Establishing
and implementing appropriate internal controls regarding the accuracy
and integrity of information about consumers furnished to consumer
reporting agencies, such as by implementing standard procedures and
verifying random samples of information provided to consumer reporting
agencies.
(e) Training staff that participates
in activities related to the furnishing of information about consumers
to consumer reporting agencies to implement the policies and procedures.
(f) Providing for appropriate and effective oversight
of relevant service providers whose activities may affect the accuracy
or integrity of information about consumers furnished to consumer
reporting agencies to ensure compliance with the policies and procedures.
(g) Furnishing information about consumers to consumer
reporting agencies following mergers, portfolio acquisitions or sales,
or other acquisitions or transfers of accounts or other obligations
in a manner that prevents re-aging of information, duplicative reporting,
or other problems that may similarly affect the accuracy or integrity
of the information furnished.
(h) Deleting, updating,
and correcting information in the furnisher’s records, as appropriate,
to avoid furnishing inaccurate information.
(i)
Conducting reasonable investigations of disputes.
(j) Designing technological and other means of communication with
consumer reporting agencies to prevent duplicative reporting of accounts,
erroneous association of information with the wrong consumer(s), and
other occurrences that may compromise the accuracy or integrity of
information provided to consumer reporting agencies.
(k) Providing consumer reporting agencies with sufficient identifying
information in the furnisher’s possession about each consumer about
whom information is furnished to enable the consumer reporting agency
properly to identify the consumer.
(l) Conducting
a periodic evaluation of its own practices, consumer reporting agency
practices of which the furnisher is aware, investigations of disputed
information, corrections of inaccurate information, means of communication,
and other factors that may affect the accuracy or integrity of information
furnished to consumer reporting agencies.
(m) Complying
with applicable requirements under the Fair Credit Reporting Act and
its implementing regulations.
